Case 1:21-cv-02524 Document 1 Filed 10/04/21 Page 1 of 15
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`IN THE UNITED STATES DISTRICT COURT OF MARYLAND
`BALTIMORE DIVISION
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` Civil Case No.: __________________
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`THE ESTATE OF HENRIETTA LACKS
`1304 Kitmore Road
`Baltimore, Maryland 21239
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` PLAINTIFF
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`VS-
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`THERMO FISHER SCIENTIFIC INC.
`Serve: Capitol Corporate Services, Inc.
`Resident Agent
`3206 Tower Oaks Blvd.
`4th Floor
`Rockville, Maryland 20852
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` DEFENDANT
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`CIVIL COMPLAINT AND REQUEST FOR JURY TRIAL
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`Plaintiff The Estate of Henrietta Lacks (“Plaintiff” or “Ms. Lacks”), by and through their
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`undersigned counsel, brings this Complaint against Defendant Thermo Fisher Scientific, Inc.
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`(“Thermo Fisher Scientific” or the “Company”), and states as follows:
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`INTRODUCTION
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`1.
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`This case is about a multibillion-dollar biotechnology corporation, Thermo Fisher
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`Scientific, making a conscious choice to sell and mass produce the living tissue of Henrietta Lacks,
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`a Black woman, grandmother, and community leader, despite the corporation’s knowledge that
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`Ms. Lacks’ tissue was taken from her without her consent by doctors at Johns Hopkins Hospital
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`and a racially unjust medical system.
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`2.
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`Medical research has a long, troubled racial history. The exploitation of Henrietta
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`Lacks represents the unfortunately common struggle experienced by Black people throughout US
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`history. Indeed, Black suffering has fueled innumerable medical progress and profit, without just
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`compensation or recognition. Various studies, both documented and undocumented, have thrived
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`off the dehumanization of Black people.
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`3.
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`In the 1950s, a group of white doctors at Johns Hopkins preyed on Black women
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`with cervical cancer. While treating Black women in racially segregated wards, the white doctors
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`would cut away tissue samples from their patients’ cervixes without their patients’ knowledge or
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`consent. A leading figure in this conspiracy—Dr. George Gey, then head of tissue culture research
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`at Hopkins—once proclaimed himself “the world’s most famous vulture, feeding on human
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`specimens almost constantly.”
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`4.
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`To be clear, these tissue samples were not taken for purposes of medical treatment
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`or with the informed consent of those operated upon.
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`5.
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`Henrietta Lacks was one of the victims of this conspiracy. Ms. Lacks was admitted
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`to the racially segregated ward at Johns Hopkins Hospital—one of the only hospitals that would
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`treat Black patients—for a malignant tumor on her cervix. On February 5, 1951, during a surgical
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`procedure and with her under anesthesia, a white doctor at Johns Hopkins used a sharp knife to cut
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`two parts of Ms. Lacks’ cervix away under the guise of treating her cervical cancer with radium.
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`This surgical procedure to harvest Ms. Lacks’ tissue was not medically necessary and was not an
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`operation to which Ms. Lacks consented. Nor was she warned about the risks of the aggressive
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`course of treatment she was subjected to, which left her infertile. Months later, when Ms. Lacks
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`was told that the course of treatment for her cancer had left her infertile, she stated clearly that she
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`would never have agreed to be treated had she been informed of the risk of infertility. The
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`treatment was also completely ineffective. Henrietta Lacks ultimately died of cervical cancer on
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`October 4, 1951.
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`6.
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`The cells taken from Henrietta Lacks have unique properties. While most cell
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`samples die shortly after they are removed from the body, Ms. Lacks’ cells survived and
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`reproduced in the laboratory. This exceptional quality meant that it was possible to cultivate Ms.
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`Lacks’ cells into a cell line that could reproduce indefinitely in laboratory conditions—an immortal
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`cell line. Indeed, Ms. Lacks’ cells were the first known immortalized human cell line. Medical
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`researchers refer to Henrietta Lacks’ cultivated cell line as the HeLa cell line, using the first letters
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`of Ms. Lacks’ first and last names.
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`7.
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`The origins of this cell line were not known to medical researchers outside Johns
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`Hopkins for decades after Ms. Lacks’ death. Before the revelation that HeLa cells were obtained
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`without Ms. Lacks’ consent, medical researchers used HeLa cells to develop a huge number of
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`scientific and medical innovations, including the polio vaccine, gene mapping, in vitro fertilization
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`and many more. The HeLa cell line is one of the most important and widely used cell lines in
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`human history. But Henrietta Lacks was never told why her tissue was taken and never gave
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`permission for her cells to be used as they have been.
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`8.
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`Today, however, the origins of the HeLa cell line have been widely publicized—
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`including by a bestselling book, a film starring Oprah Winfrey, and thousands of media reports.
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`The publicity surrounding Ms. Lacks’ cells is such that no reasonable person who works with
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`HeLa cells could be unaware of the fact the cell line was wrongfully taken from Henrietta Lacks’
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`body without her consent or knowledge. There is a widespread consensus today that the theft of
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`Ms. Lacks’ cells was profoundly unethical and wrong.
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`9.
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`Despite this, one of the largest biotechnology companies in the world—Thermo
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`Fisher Scientific—has continued to mass-produce and sell Ms. Lacks’ bodily tissue for its own
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`profit without permission of Ms. Lacks’ Estate. To this day, Thermo Fisher Scientific cultivates
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`and sells HeLa cells in multiple product lines to buyers across the globe.
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`10.
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`In other words, Thermo Fisher Scientific literally sells Ms. Lacks’ cellular material,
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`develops and manufactures cellular products incorporating HeLa cells, and seeks intellectual
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`property rights on these products, staking a claim to the genetic material of Ms. Lacks. Thermo
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`Fisher Scientific has appropriated Ms. Lacks’ genetic material for its own pecuniary gain, all
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`without payment, permission, or approval from the Lacks Estate or family.
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`11.
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`In the last several years, Thermo Fisher Scientific has made staggering profits by
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`using the HeLa cell line—all while Ms. Lacks’ Estate and family haven’t seen a dime. In 2020,
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`Thermo Fisher Scientific recorded $32.22 billion in revenue. These commercialization efforts
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`occurred after the widespread publicity around the origins of the HeLa cell line. Thermo Fisher
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`Scientific has known that HeLa cells were stolen from Ms. Lacks and chose to use her body for
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`profit anyway. A human being—Henrietta Lacks—is behind every cell, every sample sold by
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`Thermo Fisher Scientific.
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`12.
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`Because of Thermo Fisher Scientific’s actions, Henrietta Lacks’ children and
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`grandchildren have been forced to live with the reality that living tissue of their mother or
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`grandmother is being sold by a large corporation against her and her family’s will. This robs the
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`family of one of the most basic comforts any grieving person can ask for—the knowledge that a
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`loved one’s body has been treated with respect.
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`13.
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`Beyond this harm, the widespread dissemination of Henrietta Lacks’ tissue means
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`Ms. Lacks’ genetic information is now commonly available—and, as a consequence, some of the
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`most private information about Ms. Lacks and her family has been exposed to the general public.
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`14.
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`Thermo Fisher Scientific’s choice to continue selling HeLa cells in spite of the cell
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`lines’ origin and the concrete harms it inflicts on the Lacks family can only be understood as a
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`choice to embrace a legacy of racial injustice embedded in the US research and medical systems.
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`Black people have the right to control their bodies. And yet Thermo Fisher Scientific treats
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`Henrietta Lacks’ living cells as chattel to be bought and sold.
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`15.
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`The Estate of Henrietta Lacks brings a single cause of action—unjust enrichment—
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`against Thermo Fisher Scientific for its choice to profit from the unlawful conduct of Johns
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`Hopkins’ doctors. Under settled law, as articulated in the Third Restatement of Restitution “a
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`defendant who is enriched by misconduct and who acts [] with knowledge of the underlying wrong
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`to the claimant” is a conscious wrongdoer liable for its profits. Restatement (Third) of Restitution
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`and Unjust Enrichment § 51(3) (2011). Put simply, because it made the conscious choice to profit
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`from the assault of Henrietta Lacks, Thermo Fisher Scientific’s ill-gotten gains rightfully belong
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`to Ms. Lacks’ Estate.
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`PARTIES
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`16.
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`Plaintiff Henrietta Lacks was a natural person, resident of Baltimore County,
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`Maryland, and citizen of the state of Maryland. The executor of Ms. Lacks’ estate is Ron L. Lacks,
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`Ms. Lacks’ grandson.
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`17.
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`Thermo Fisher Scientific Inc. is a Delaware corporation headquartered in Waltham,
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`Massachusetts. As used in this complaint, “Thermo Fisher Scientific” refers both to Thermo Fisher
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`Scientific Inc. and to its subsidiaries, affiliates, agents, and other entities within its control that
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`have owned, manufactured, distributed, monitored, or sold HeLa cells or related products.
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`18.
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`Thermo Fisher Scientific is one of the largest biotechnology companies in the
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`world. Its stock trades on the New York Stock Exchange and as a component of both the S&P 100
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`and S&P 500. It has a market capitalization of more than $200 billion and revenues of more than
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`$30 billion. In 2019, its CEO, Marc Casper, received approximately $20 million in compensation.
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`JURISDICTION AND VENUE
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`19.
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`This Court has jurisdiction over the subject matter of this action based upon
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`diversity of citizenship pursuant to 28 U.S.C. § 1332 in that Plaintiff is not from the same state as
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`Defendants, and the amount in controversy exceeds $75,000.
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`20.
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`Venue is proper under 28 U.S.C. § 1391 because a substantial part of the events or
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`omissions giving rise to Plaintiff’s claims occurred in this district.
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`21.
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`Thermo Fisher Scientific has purposefully availed itself of this forum. Thermo
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`Fisher Scientific maintains major laboratories and cell storage sites in Fredrick, Maryland and
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`Rockville, Maryland. These facilities are used for cell therapy clinical trial support services. On
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`information and belief, these facilities are one of the major hubs of Thermo Fisher Scientific’s
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`commercialization of HeLa cells.
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`22.
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`Thermo Fisher Scientific has further purposefully availed itself of this forum by
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`commercializing HeLa cells despite its knowledge that the cells were obtained in Baltimore
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`County, Maryland, through the unlawful conduct described elsewhere in the complaint.
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`FACTS
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`23.
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`In 1951, the chair of gynecology at Johns Hopkins—Dr. Richard Wesley
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`TeLinde—faced widespread criticism for his practice of frequently removing the cervix, uterus,
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`and substantial portions of the vagina of patients with carcinoma in situ, a condition not believed
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`to be deadly at the time.
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`24.
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`TeLinde believed that by showing that carcinoma in situ behaved similarly to other
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`forms of cervical cancer that were known to be deadly in the laboratory, he would be able to prove
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`his aggressive surgical techniques were justified, and repair his tarnished reputation. TeLinde thus
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`proposed to Dr. George Gey, then head of tissue research at Johns Hopkins, that TeLinde would
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`provide samples of cervical cancer, taken from his patients without their knowledge or consent to
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`Gey, if Gey would use those sample in his research and attempt to cultivate those cells in a form
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`that could survive in a laboratory.
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`25.
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`TeLinde’s offer meshed well with Gey’s research interests. Virtually all human
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`cell samples at the time died quickly in laboratory conditions. Gey wanted to attempt to cultivate
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`a cell line that would be able to survive indefinitely in a lab—an immortal cell line. Gey had little
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`understanding of why human cells died in laboratory conditions. And thus, Gey tried repeating
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`the process of creating human cell samples that could survive in laboratory conditions over and
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`over again—a process that required more and more samples. TeLinde’s proposal of an endless
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`supply of samples thus suited Gey perfectly, and he agreed to the deal.
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`26.
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`To get Gey samples, TeLinde directed the doctors under his supervision to take
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`tissue samples from Black patients in Johns Hopkins’ segregated wards with cervical cancer.
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`While treating Black women in racially segregated wards, the white doctors under TeLinde’s
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`supervision would cut away tissue samples from their patients’ cervixes without their patients’
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`knowledge or consent. As one doctor acting under TeLinde’s supervision callously summarized,
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`“Hopkins, with its large indigent [B]lack population, had no dearth of clinical material.”
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`27.
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`This horrifying dehumanization of Black patients and abuse of trust sadly had all
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`too much precedent in then-recent medical history. At the same time as TeLinde and Gey
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`concocted their scheme, the U.S. Public Health Service, working with the Tuskegee Institute in
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`Macon, Alabama, denied hundreds of Black men widely available treatment for syphilis to enable
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`them to study how the disease progressed when untreated. By the time this abusive study was
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`disclosed to the public in July 1972, 28 participants had died from syphilis, 100 more had passed
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`away from related complications, at least 40 spouses had been diagnosed with it, and the disease
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`had been passed to 19 children at birth.
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`28.
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`The list of abuses is long. Another example is the medical practice known as the
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`“Mississippi Appendectomy” beginning in the 1920s. The Mississippi Appendectomy was the
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`systematic forced sterilization of poor Black women without the women’s knowledge or consent.
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`Doctors performed the hysterectomies under the pretense of appendectomies in order to prevent
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`poor Black women from reproducing and to give young, inexperienced doctors the opportunity to
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`practice the hysterectomy procedure. These sterilizations reflected a blatant disregard for basic
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`human rights.
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`29.
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`Similarly, in the Second World War, the United States tested mustard gas and other
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`chemical agents on Black men, and then threatened the soldiers who complained with prison time
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`to keep them quiet. Too often, the history of medical experimentation in the United States has
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`been the history of medical racism.
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`30.
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`In January 1951, Henrietta Lacks was diagnosed with cervical cancer at Johns
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`Hopkins.
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`31.
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`Henrietta Lacks’
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`treating doctor—acting under TeLinde’s supervision—
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`recommended an aggressive course of treatment: inserting rods of radium, a radioactive substance,
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`into her body. This treatment approach required that Lacks be placed under anesthesia—providing
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`an opportunity for a surgeon working for TeLinde to collect the tissue samples from Ms. Lacks.
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`This procedure was also certain to render Ms. Lacks infertile.
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`32.
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`Henrietta Lacks was not informed that Johns Hopkins planned to take samples of
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`her cervix. She did not consent to this surgical procedure or any such sampling. Taking a tissue
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`sample is not medically necessary to conduct radium treatment, nor was it common practice in
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`radium treatment at the time. Ms. Lacks was also not told that the radium treatment she would be
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`subjected to would render her infertile.
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`33.
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`On February 5, 1951, while Henrietta Lacks was unconscious, a surgeon working
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`under TeLinde’s supervision cut two circular samples of tissue, each about three quarters of an
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`inch across, from her cervix. These samples were then given to Gey for experimentation.
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`34.
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`Gey then attempted, once again, to create a cell line that could survive in laboratory
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`conditions. Gey’s efforts in cultivating the HeLa cell line were not meaningfully different than his
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`prior, failed efforts. However, unknown to Gey—and for reasons that the scientific community
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`would not come to understand until decades later—Ms. Lacks’ cells had unique properties that
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`meant they were able to survive in laboratory conditions. Gey was finally able to create the
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`immortal cell line he craved.
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`35.
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`As Gey worked to cultivate the stolen cells, Henrietta Lacks died of cervical cancer
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`on October 4, 1951. She was buried in an unmarked grave.
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`36.
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`Indeed, around the same time Henrietta Lacks passed away, Gey appeared on
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`television, holding a vial of Ms. Lacks’ cells, to present his purported contribution to the fight
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`against cancer. Gey introduced to the world the first successfully grown “immortal” human cell
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`line.
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`37.
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`Scientists all over the world were given HeLa cells for free to conduct their own
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`studies. Because HeLa cells were the first human cells that could survive indefinitely in laboratory
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`conditions, scientists were able to use them for medical research that might well not have been
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`possible without them. In the decades that followed, the HeLa cell line became an essential
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`resource for medical research in labs worldwide. HeLa was used to test the first polio vaccine, to
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`understand the effects of radiation on human cells, to develop treatment for sickle cell anemia, and
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`in countless scientific papers.
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`38.
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`However, Ms. Lacks’ estate and family never received any part of the billions of
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`dollars that HeLa cells brought (and continue to bring) to many companies. In fact, despite the
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`widespread use of HeLa cells, for decades, the facts surrounding the origin of the HeLa cell line
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`were unknown. Gey and Johns Hopkins went to great lengths to keep the origins of the HeLa cell
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`line secret. As a result, for decades, the global scientific and medical communities were unaware
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`that the HeLa cell line was the product of the assault of Henrietta Lacks. Indeed, for many years,
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`even Henrietta Lacks’ real name was not known to the public—Gey claimed the cells came from
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`a person named Helen Lane to conceal the cells’ true origin.
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`39.
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`In recent years, the origins of the HeLa cell line have become widely known.
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`Today, the fact that HeLa cells were taken from Henrietta Lacks without her knowledge or consent
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`has been extensively publicized. The extensive publicity of the taking of parts of Henrietta Lacks’
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`body without her consent includes:
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`(a)
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`A nonfiction book which spent 75 weeks on the New York Times Best
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`Seller list, including a substantial period in the number one slot;
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`(b) Mentions in more than 2,700 academic articles discussing issues of patient
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`(c)
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`(d)
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`consent and medical ethics;
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`A movie starring Oprah Winfrey that aired on HBO;
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`Tens of thousands of media articles in the international, national, and local
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`press; and
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`(e)
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`Official recognition of Henrietta Lacks’ contributions to medical science by
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`the United States House of Representatives.
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`40.
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`Any reasonable person working with HeLa cells—especially a person with the
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`resources of Thermo Fisher Scientific—would be aware of the origin of the HeLa cell line,
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`including that the cells were taken from Ms. Lacks without her consent.
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`41.
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`Indeed, Thermo Fisher Scientific has publicly admitted that it is aware of the fact
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`HeLa cells were taken from Henrietta Lacks without her consent. The company hosts an article
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`on its corporate website that states HeLa cells were removed from Ms. Lacks and used for scientific
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`research despite the fact that “[Ms.] Lacks and her family were unaware that her tissue was used
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`in this way.” Similarly, in another article on its corporate website, Thermo Fisher Scientific
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`acknowledges “the widespread but unsanctioned use of HeLa cells from Henrietta Lacks.”
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`42.
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`Despite their awareness of the origins of the HeLa cell line, Thermo Fisher
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`Scientific made the choice to use Henrietta Lacks’ body for their own profit. Thermo Fisher
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`Scientific began mass producing HeLa cells for commercial research use, reaping millions of
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`dollars in profits that would never have been possible without Henrietta Lacks’ cells. Thermo
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`Fisher Scientific never sought or received permission from the Estate of Henrietta Lacks to do so.
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`43.
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`To this day, Thermo Fisher Scientific cultivates and sells HeLa cells, including the
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`following product lines—each of which is currently available for sale on the company’s website:
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`(a)
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`Pierce HeLa Protein Digest Standard
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`(b)
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`Pierce HeLa Digest/PRTC Standard
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`(c)
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`T-REx HeLa Cell Line
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`(d)
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`(e)
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`(f)
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`Cervical Adenocarcinoma (HeLa-S3) Total RNA
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`Human Cervical Adenocarcinoma (HeLa-S3) Total RNA
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`Cell Sensor ESRE-bla HeLa Cell Line
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`(g)
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`Cell Sensor HSE-bla HeLa Cell Line
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`(h)
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`LanthaScreen c-Jun (1-79) HeLa Cell Line
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`(i)
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`(j)
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`Cell Sensor T-REx NICD CSL-bla HeLa Cell Line
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`Cell Sensor T-REx FOXO3 DBE-bla HeLa Cell Line
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`(k)
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`1-Step Human Coupled IVT Kit – DNA
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`(l)
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`1-Step Human High-Yield Maxi IVT Kit.
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`44.
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`On information and belief, Thermo Fisher Scientific’s efforts to commercialize
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`HeLa cells are not limited to the HeLa cell lines available for sale to the public. The company also
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`offers contract development and manufacturing services to other biotechnology companies. Those
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`services involve using HeLa cells to support scientific research by other companies—in exchange
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`for substantial payments to Thermo Fisher Scientific. Additionally, HeLa cells are also a part of
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`other products the company manufactures, sells, or otherwise profits from.
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`45.
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`In other words, Thermo Fisher Scientific’s business is to commercialize Henrietta
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`Lacks’ cells—her living bodily tissue—without the consent of or providing compensation to Ms.
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`Lacks’ Estate. All the while, Thermo Fisher Scientific understands—indeed, acknowledges on its
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`own website—that this genetic material was stolen from Ms. Lacks. Thermo Fisher Scientific’s
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`business is nothing more than a perpetuation of this theft.
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`46.
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`Thermo Fisher Scientific has made and continues to make vast amounts of
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`money—in the millions of dollars—from its commercialization of HeLa cells.
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`COUNT I
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`FOR UNJUST ENRICHMENT
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`47.
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`Plaintiff incorporates ¶¶1-46 by reference.
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`48.
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`Thermo Fisher Scientific was unjustly enriched because it received a benefit from
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`Henrietta Lacks, understood it received a benefit from Ms. Lacks, and did so in circumstances in
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`which acceptance or retention of the benefit was inequitable without payment or permission.
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`49.
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`Acceptance or retention of the HeLa cell line was inequitable without payment or
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`permission because the HeLa cell line was created through breach of a relation of trust and
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`confidence.
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`50.
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`Acceptance or retention of the HeLa cell line was inequitable without payment or
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`permission because the HeLa cell line was created through the unlawful conduct described above.
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`51.
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`Acceptance or retention of the HeLa cell line was inequitable without payment or
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`permission because of the totality of circumstances surrounding the creation and acquisition of the
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`HeLa cell line.
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`52.
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`Thermo Fisher Scientific acted with knowledge of the underlying wrong to
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`Henrietta Lacks or despite a known risk that the conduct in question violated the rights of Ms.
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`Lacks. Defendants are thus liable for their net profits incurred as a result of their unjust
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`enrichment.
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`PRAYER FOR RELIEF
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`WHEREFORE, plaintiff requests that the Court, after trial on the merits, grant the
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`following relief and judgment:
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`A.
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`Order Thermo Fisher Scientific to disgorge the full amount of its net profits
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`obtained by commercializing the HeLa cell line to the Estate of Henrietta Lacks;
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`B.
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`Enter an order permanently enjoining Thermo Fisher Scientific from using the
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`HeLa cell line without the permission of the Estate of Henrietta Lacks;
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`C.
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`Impose a constructive trust in favor of the Estate on all HeLa cells possessed by
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`Thermo Fisher Scientific, all related intellectual property, and all proceeds related to use thereof;
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`D.
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`Awarding plaintiff her reasonable costs and expenses incurred in this action,
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`including counsel fees and expert fees; and
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`E.
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`Awarding such other and further relief as the Court may deem just and proper.
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`JURY DEMAND
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`Plaintiff hereby demands a trial by jury.
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`DATED: October 4, 2021
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`
`
`
`
`/s/ Kim Parker
`Kim Parker, Esquire
`Federal Bar No.: 23894
`LAW OFFICES OF KIM PARKER, P.A.
`2123 Maryland Ave.
`Baltimore, MD 21218
`Telephone: 410-234-2621
`Fax: 443-486-1691
`kp@kimparkerlaw.com
`
`Christopher A. Seeger*
`Jeffrey S. Grand*
`Christopher L. Ayers*
`James Bilsborrow*
`Nigel P. Halliday*
`SEEGER WEISS LLP
`55 Challenger Road, 6th Floor
`Ridgefield Park, NJ 07660
`Telephone: 212-584-0700
`Fax: 212-584-0799
`cseeger@seegerweiss.com
`jgrand@seegerweiss.com
`cayers@seegerweiss.com
`jbilsborrow@seegerweiss.com
`nhalliday@seegerweiss.com
`
`Ben Crump*
`Christopher O'Neal*
`BEN CRUMP LAW, PLLC
`717 D Street, N.W. Suite 310
`Washington D.C. 20004
`Telephone: 860.922.3030
`ben@bencrump.com
`chris@bencrump.com
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`*Application for Pro Hac Vice Admission
`Pending
`ATTORNEYS FOR
`THE ESTATE OF HENRIETTA LACKS
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`Case 1:21-cv-02524 Document 1 Filed 10/04/21 Page 15 of 15
`Case 1:21-cv-02524 Document1 Filed 10/04/21 Page 15 of 15
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